IRS and Treasury have released final and proposed regulations regarding the new global intangible low-taxed income (GILTI) regime. Both sets of regulations provide guidance on determining the amount of GILTI included in the gross income of certain U.S. shareholders of foreign corporations, as well as other rules more broadly applicable for purposes of subpart F income. The proposed regulations provide an elective high-tax income exclusion and adopt an expanded aggregate approach to partnerships with respect to Sec. 951, in addition to Sec. 951A. Concurrent with the release of final regulations, IRS also released temporary and proposed regulations on Sec. 245A, portions of which relate to GILTI.
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